Law Office of Kenneth Muhammad

Attorney At Law
3675 Crestwood Parkway
Suite 400
Duluth, Georgia 30096

Telephone: 404-618-0910
Fax: 404-267-1822
Email: km@lawofficekm.com

March 22, 2016

VIA FAX: 916-808-7672
EMAIL: clerk@cityofsacramento.org
AND U.S. MAIL
Shirley Concolino, City Clerk
City of Sacramento
915 I Street
5th Floor, New City Hall Bldg.
Sacramento, CA 95814
RE:

Notice of Claim Against City of Sacramento and Mayor Kevin Johnson

Dear Ms. Concolino:

This letter serves as notice to the City of Sacramento that the following parties have a
claim against the City of Sacramento and Mayor Kevin Johnson for Defamation and Tortious
Interference with a Contractual Relationship: Mayor Michael Blunt, Mayor Robert Bowser,
Mayor James Walls, Mayor Frank Wilson, Mayor Gary Richardson, Mayor Frank Jackson,
Mayor Earnest Nash, Mayor John Overton, Jr., Mayor Evelyn Winn Dixon, Deputy Mayor
Donald Smith, Mayor Larry Bryant, Mayor James Knox, Mayor Otis Wallace, and Mayor
Antonio Blue. Each of the aforementioned parties shall be referred to as Claimants
hereinafter. Notice is also hereby provided that the Conference of Black Mayors, Inc. has a
claim against the City of Sacramento and Mayor Kevin Johnson for Tortious Interference with a
Contractual Relationship.
This claim arises from Mayor Kevin Johnsons involvement with the National
Conference of Black Mayors, Inc. (NCBM) Mayor Johnson assumed the presidency of this
organization in late May 2013 in a disputed election. Mayor Johnson filed a Chapter 7
bankruptcy proceeding in April 2014 attempting to liquidate NCBM against the will of the
Claimants, who were members of the board of directors at the time. Claimants have filed a
motion to dismiss the bankruptcy proceeding on the grounds that Mayor Johnson filed the
bankruptcy without full board approval. The motion to dismiss is currently pending. While the
bankruptcy case is pending, the bankruptcy trustee retains full control over the organization.
Consequently, the Claimants have elected only to pursue claims against the City of Sacramento
and Mayor Kevin Johnson for injuries sustained by each of them in their individual capacities.

Claimants assert that City of Sacramento staff and volunteers and Mayor Kevin Johnson
conducted an organized conspiracy to:
1) Defamation. Claimants allege that Mayor Kevin Johnson, city staff and volunteers
issued press releases and other communications to print, radio, and television news
media stating that the leadership of NCBM, which included Claimants, mismanaged
the affairs of the organization, allowed funds to be misappropriated, and otherwise
engaged in negligent conduct. Mayor Kevin Johnson, city staff and volunteers knew
that the information that they provided to the media was entirely false. This claim has
been ongoing from March 2013 through the present. These actions were a part of a
scheme devised by Mayor Kevin Johnson, his staff and volunteers, and the law firm
of Ballard Spahr to oust NCBMs executive director, Vanessa Williams. Mayor
Kevin Johnsons ultimate goal was to liquidate NCBM, a forty year-old institution,
and to start his new organization now known as the African American Mayors
Association (AAMA).
2) Interference with Contractual Relationship. Claimants allege that Mayor Kevin
Johnson, city staff and volunteers conspired to seize control of the organization from
Claimants, as members of the board of directors. They used the law firm of Ballard
Spahr to illegally control BB&T bank records for which they had no lawful access.
They participated in an elaborate plan devised to keep Claimants away from
purported board meetings, and to remove access to both tangible and intangible
property of the organization. Claimants became aware of these activities, which took
place in 2013 and 2014, within the last two months.
3) Interference with Contractual Relationship. Conference of Black Mayors, Inc. alleges
that Mayor Kevin Johnson and city staff and volunteers intentionally interfered with
the organizations ability to fulfill a contract with the City of Hamilton, Bermuda.
City staff and volunteers who participated in each of the above acts included Stephanie
Mash, Aisha Lowe, Ben Sosenko, Mariah Sheriff, Cassandra Jennings, Tracy Stigler, and Meera
Kirshnan. Claimants have suffered damages as a result of the unlawful acts of Mayor Kevin
Johnson and the above-named city staff and volunteers.
Please feel free to contact me if you would like to discuss this claim, or to receive
additional information. Thank you.

Sincerely,

Kenneth Muhammad